Michigan is permissive about who may perform a task and strict about who may own the company doing it. Most operators have that backwards.
Under MCL 333.16215 a licensee may delegate to a licensed or unlicensed individual otherwise qualified by education, training or experience, where the act falls within the delegator’s own scope. Michigan defines delegation as authorisation to perform acts that are within the delegator’s scope and not within the delegatee’s, and which absent that authorisation would be the illegal practice of a licensed profession. The statute ties delegation to supervision: you cannot delegate without supervising.
What Michigan actually requires
- A Michigan-licensed physician who retains medical judgment and direction of clinical care — only individuals licensed to practise medicine may exercise it.
- Delegation under MCL 333.16215 that is genuine authorisation, matched to the individual delegatee’s education, training and experience, and paired with actual supervision.
- A professional corporation in which, because medicine is a Public Health Code service, every shareholder is licensed or legally authorised in Michigan to render the same professional service (Professional Service Corporation Act, Act 192 of 1962, § 4(3)).
- Written protocols. A medical director who is a silent partner does not satisfy the supervision the delegation statute assumes.
- Recognition that injectables, lasers and IV therapy are medical acts under the Public Health Code, enforced by LARA and the Michigan Board of Medicine.
Who may do what in Michigan
| Licence | What they may do |
|---|---|
| MD or DO | Independent; may delegate within their own scope |
| Licensed delegatee (PA, NP, RN) | May receive delegated acts within the delegator’s scope, under supervision |
| Unlicensed individual | May receive delegated acts if qualified by education, training or experience — and only under supervision |
| LPN | Works under the supervision of an RN, physician or dentist |
| PC shareholder | Must be licensed to render the same professional service as the corporation |
The shareholder rule is the one that quietly kills deals. A plan to give a nurse practitioner, a PA and an investor equity in the same medical PC does not survive § 4(3): for a Public Health Code service, all shareholders must be able to render that same service.
What MDside provides in Michigan
- A Michigan-licensed MD or DO as medical director, doing the work rather than lending a name.
- Delegation documents written per individual delegatee, because Michigan measures the delegation against that person’s training and experience rather than against their job title.
- The professional entity and management agreement built to Michigan rather than to a national template.
- Licensed physicians for the good faith exams behind prescriptions and injectables.
- 503A and 503B pharmacy relationships and lab draws.
See what is included, or book a call and tell us which states you operate in.
Read the detail on Michigan
Frequently asked questions
Can unlicensed staff perform medical acts in Michigan?
MCL 333.16215 permits delegation to a licensed or unlicensed individual otherwise qualified by education, training or experience, for acts within the delegator’s scope, under supervision. The scope and the supervision are the limits.
Who may hold shares in a Michigan medical PC?
For a professional service included in the Public Health Code, all shareholders must be licensed or legally authorised in Michigan to render the same professional service.
Can a nurse practitioner own a Michigan med spa?
Not as a shareholder of a medical professional corporation alongside physicians, given the same-service shareholder requirement. Structure options should be confirmed with Michigan counsel.
General information about Michigan practice structure and med spa regulation, not legal advice. Statutes, board rules and scope-of-practice requirements change. Confirm your obligations with healthcare counsel licensed in Michigan.